Earlier this month, the US sanctioned the same 17 Saudi nationals under its Global Magnitsky Laws (Executive Order 13818) for “serious human rights abuse resulting from their roles in the killing of Jamal Khashoggi” (see previous blog).

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OFAC has designated 2 Iranian nationals, Ali Khorashadizadeh and Mohammad Ghorbaniyan, “who helped exchange digital currency (bitcoin) ransom payments into Iranian rial on behalf of Iranian malicious cyber actors involved with the SamSam ransomware scheme”. For the first time, OFAC has also publicly identified 2 digital currency addresses associated with these 2 individuals, in which over 7000 bitcoin transactions (worth millions of US dollars) were processed through. These cyber-related designations were made pursuant to Executive Order 13694, which imposes US asset freezes and travel bans, and could subject others to secondary sanctions if they engage in transactions with the 2 listed individuals. See OFAC Notice, US Treasury Press Release, and Two New Digital Currency-Related FAQs.

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OFAC has announced a $87,507 settlement with Virginia-based Cobham Holdings Inc in order to settle on behalf of its former subsidiary, Aeroflex/Metelics Inc, three violations of the Ukraine-Related Sanctions Regulations. Specifically, between July 2014 and January 2015, Metelics indirectly exported defence components for end-use by Russian defence company Almaz Antey Telecommunications LLC (AAT). At all relevant times, although AAT was not explicitly identified on the SDN List, it was owned 50% or more by Joint-Stock Concern Almaz-Antey, which OFAC had sanctioned on 16 July 2014 (two weeks before Metelics made its first shipment of defence components). See OFAC Notice and Enforcement Information.

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US President Donald Trump has issued a new Executive Order targeting Nicaragua. It imposes US asset freezes and travel bans on (inter alia) individuals and entities engaged in corruption, serious human rights abuses, and actions or policies which undermine democracy, or threaten the peace, security or stability of Nicaragua. It also targets officials of the Nicaraguan Government who have served at any time on or after 10 January 2007.

Pursuant to this new Executive Order, OFAC has sanctioned two of Nicaraguan President Daniel Ortega’s associates: Rosario Maria Murillo De Ortega, Vice President of Nicaragua and First Lady, and Nestor Moncada Lau, national security advisor to the President and Vice President. As a result, they will now be subject to US asset freezes and travel bans. See OFAC Notice, US Treasury Press Release, and White House Fact Sheet.

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The EU General Court has allowed the Kurdistan Workers’ Party’s (PKK) application to annul its 2014 to 2017 terrorism sanctions listings – see judgment: T-316/14. The Court held that the EU had breached its obligation to state reasons because (in summary) a “significant” period of time (over 10 years) had elapsed since the adoption of the material justifying the PKK’s initial designation in 2002, of which was no longer sufficient in determining whether the PKK’s involvement in terrorist activities persisted at the time when the contested acts were adopted between 2014 and 2017.

In 2008, the PKK had successfully challenged its June 2002 terrorism sanctions listing before the EU Court (judgment: T-229/02), on the basis that the EU had again breached its obligation to state reasons.

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The EU General Court has upheld the 2016 and 2017 Egypt sanctions listings (targeting the misappropriation of state funds) of Suzanne Thabet, the wife of the former President Mubarak, their sons, Gamal Mubarak and Alaa Mubarak, and their sons’ wives, Khadiga El Gammal and Heidy Rasekh. See joined judgment: T-274/16 and T-275/16.

The Court did not accept the applicants’ arguments that there was no legal basis for their listings, that the Egyptian judicial proceedings did not respect their fundamental rights, and that the EU had infringed rights of the defence and the principle of proportionality. See EU Press Release.

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Three individuals – Alexander Samuel George, Paul Robert Attwater, and Iris Louise Attwater – have been convicted in the UK of evading export controls in relation to Iran.

Alexander George, who was sentenced yesterday to 2½ years’ imprisonment, shipped military items to Iran, including Russian MiG and US F4 Phantom parts, through various companies and countries without the appropriate licence. Paul Attwater and his wife Iris, who each received suspended sentences of 6 months’ imprisonment last month, sourced dual-use aircraft parts from the USA and shipped them to Alexander George’s companies in Malaysia and Dubai, which then sent them to Iran.

The offenders were also disqualified from being a company director (9 years for Alexander George, and 6 years each for Paul and Iris Attwater). POCA proceedings will now follow to recover the money made from the criminality. See UK Press Release.

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About this blog

This blog sets out the latest developments in the law of European Union sanctions.

We include all kinds of European Union sanctions: those that derive from the United Nations and autonomous sanctions, measures designed to combat terrorist financing, nuclear proliferation, and human rights violations in third country regimes, and those that seek to restore misappropriated assets.

The 'sanctions in force' section contains an up-to-date list of European sanctions in force. The blog covers developments in the case law of the European Court of Justice and General Court, and courts in the United Kingdom. We aim to include material from other countries too, including the USA.